Publications

On June 9, 2015, the OIG issued a Fraud Alert addressing physician compensation arrangements. While brief, the Fraud Alert provides an important reminder that financial arrangements between physicians and providers are targets of the OIG’s enforcement efforts. The Fraud Alert is clearly intended to emphasize that, in addition to hospitals, […]

Subordinated debt instruments are making a comeback, with private offerings and pooled investments gaining favor among a number of bankers in the Midwest. As bankers consider whether subordinated debt is the right way to boost their balance sheets, there are at least three major legal issues to consider before making […]

Once upon a time, common sense typically governed employee misconduct investigations. In those days, employers understandably and routinely cautioned employees not to discuss pending investigations with coworkers, and protected the written statements of potentially vulnerable employees who reported coworker misconduct. Normal thinking in those “good ole days” suggested that collaboration […]

On July 31, 2014, President Obama signed the Fair Pay and Safe Workplaces Executive Order (“Order”), which would require certain prospective federal contractors to disclose labor law violations and would give agencies more guidance on how to consider labor violations when awarding federal contracts. You can access the newsletter article […]

As the farm economy tightens, the chances increase that your farm borrower may sell his or her grain without paying you the proceeds. Your borrower might have several reasons for doing so, but none of them are sufficient. For example, farmers may want to pay their input providers first, or […]